I was completely dismayed to read the recent announcement by the EPA that you were sentenced to pay $4.5 million in criminal penalties for illegally applying insecticides to wild bird food products, falsifying pesticide registration documents, distributing pesticides with misleading and unapproved labels, and distributing unregistered pesticides.
In a separate civil suit, you agreed to pay $6.0 million in civil penalties and spend an additional $2.0 million on environmental projects to resolve additional violations that include distributing or selling unregistered, canceled, or misbranded pesticides ~ including products with inadequate warnings or cautions.
You see, Scotts ~ my job is to coordinate the Oregon State University Extension Master Gardener Program. I know you are familiar with Master Gardener Programs around the United States. Over the years, you have supported many Master Gardener programs ~ including my own ~ with donations of funds or products. I believe it was in 2009, Scotts, that you gave the Oregon Master Gardener Association (a non-profit organization that is separate from, but works to support the OSU Extension Master Gardener Program) $1,000 for the purchase of coffee and snacks at our annual conference. Even though the donation was to the Oregon Master Gardener Association, I personally took a lot of heat from Master Gardeners who felt that accepting a donation from Scott's went against our commitment to sustainable gardening practices.
In answer to those many people who asked me 'why is Scotts sponsoring our coffee hours?', I reminded these concerned Master Gardeners that it is our responsibility to remain objective. In response to the many, many times I've had Master Gardeners and others ask why we don't exclusively teach organic gardening practices, or why we don't confine our advice and recommendations to only include organic options, I've reminded them that whatever our personal opinions and biases might be, it is our job to remain objective. Our responsibility is to educate clients about all of the options that are available to them ~ and then let clients choose the option that will work best for their gardening situation. When working as Master Gardeners, we don't selectively choose among all possible options, to include only those options that we personally favor.
Our job is to educate, and not legislate. We're descriptive, and not prescriptive.
I've used these lines, many times, Scotts ~ when Master Gardeners have asked me if they could ignore that your products exist, or even make recommendations against your products. Our job is to teach ~ and not to make decisions for others.
Oh, but Scotts, I'm now at a cross roads. You see, in addition to the taglines 'educate, not legislate', and 'descriptive, not prescriptive', another mantra that we repeatedly teach in the Master Gardener Program is 'the label is the law'. We repeatedly emphasize that the label on a pesticide container is a legal document, that describes legal uses for a pesticide. In Oregon, Master Gardeners must spend at least 3 and as many as 10+ hours a year taking classes where we bring in our magnifying glasses and carefully read the label on a pesticide. We talk about potential hazards of the product. We talk about precautions we can take to reduce hazards to people, pets and the environment. We talk about how it is illegal to exceed application rates, or to use a product in a way in which it is not intended. We talk about active ingredients ~ those ingredients that are intended to specifically kill, deter or repel a pest ~ and how those active ingredients must be listed on the label.
And now, after reading about your recent violations of the Federal Insecticide, Fungicide, and Rodenticide (FIFRA) Act, and then doing some more reading to discover that these violations are not your first and that the violations extend to more than 100 of your products ~ my trust in your company and your products has been damaged.
When small, untested companies market products that are little more than 'snake oil' solutions, Master Gardeners are told that they can't include those products in the list of options that they give to clients. Remember, 'research-based and reliable recommendations' is yet another Master Gardener tagline.
If your company has a history of:
- falsifying pesticide registration documents
- distributing pesticides with misleading and unapproved labels
- distributing unregistered pesticides.
- distributing or selling unregistered, canceled, or misbranded pesticides ~ including products with inadequate warnings or cautions.
I really want to know, Scotts. How can we trust you after this egregious breech of the public's trust? What should I tell the Master Gardeners that I teach? What should I tell the clients who come to us for objective, reliable advice?
Until we can be sure that your products are reliable and legal, how can we in good conscience recommend them to our clients?
Sincerely,
Gail Langellotto
home gardener, and someone who works with many, many Master Gardeners and home gardeners
